FEDERAL COMMUNICATIONS COMMISSION
Mignon L. Clyburn
Acting Chairwoman
September 27,2013
The Honorable Tim Murphy
Chairman
Subcommittee on Oversight and Investigations
Committee on Energy and Commerce
U.S. House of Representatives
2125 Rayburn House Office Building
Washington, DC 20515
Dear Chairman Murphy:
Thank you for your letter regarding the Commission's efforts to ensure that the
Video Relay Service (VRS) program is free from waste, fraud and abuse and providing
the maximum intended benefit to the deaf and hard-of-hearing communities. I instructed
Kris Monteith, Acting Chief of the Consumer and Governmental Affairs Bureau, to
coordinate a response to your questions. I appreciate your interest in this matter and am
pleased to provide the enclosed letter responding to your inquiry.
If you have any further questions, please don't hesitate to contact me.
Sincerely,
Mignon L. Clyburn
Enclosure
445 12'' Street S.W. Washington, D.C. 20554 (202) 418-1000
Federal Communications Commission
Washington, D.C. 20554
September 27,2013
The Honorable Tim Murphy
Chairman
Subcommittee on Oversight and Investigations
Committee on Energy and Commerce
U.S. House of Representatives
2125 Rayburn House Office Building
Washington, DC 20515
Dear Chairman Murphy:
Thank you for your letter regarding the Video Relay Service (VRS) program.
Enclosed please find responses to your questions which have been provided by experts
within the Commission's Consumer and Governmental Affairs and Enforcement
Bureaus, as well as the Offices of the General Counsel, Managing Director, and Strategic
Planning & Policy Analysis, each of whom play an important role in the administration
and oversight of the VRS program.
I appreciate your interest in this important matter. Should you have additional
questions or concerns, please do not hesitate to contact me.
Enclosure
Sincerely,
fr> Kris Ann Monteih
Acting Chief
Consumer and Governmental Affairs Bureau
Mignon L. Clyburn
Acting Chairwoman
FEDERAL COMMUNICATIONS COMMISSION
September 27,2013
The Honorable Michael Burgess
U.S. House of Representatives
2241 Rayburn House Office Building
Washington, DC 20515
Dear Congressman Burgess:
Thank you for your letter regarding the Commission's efforts to ensure that the
Video Relay Service (VRS) program is free from waste, fraud and abuse and providing
the maximum intended benefit to the deaf and hard-of-hearing communities. I instructed
Kris Monteith, Acting Chief of the Consumer and Governmental Affairs Bureau, to
coordinate a response to your questions. I appreciate your interest in this matter and am
pleased to provide the enclosed letter responding to your inquiry.
If you have any further questions, please don't hesitate to contact me.
Sincerely,
Mignon L. Clyburn
Enclosure
445 12'' Street S.W. Washington, D.C. 20554 (202) 418-1000
Federal Communications Commission
Washington, D.C. 20554
September 27, 2013
The Honorable Michael Burgess
U.S. House of Representatives
2241 Rayburn House Office Building
Washington, DC 20515
Dear Congressman Burgess:
Thank you for your letter regarding the Video Relay Service (VRS) program.
Enclosed please find responses to your questions which have been provided by experts
within the Commission's Consumer and Governmental Affairs and Enforcement
Bureaus, as well as the Offices of the General Counsel, Managing Director, and Strategic
Planning & Policy Analysis, each of whom play an important role in the administration
and oversight of the VRS program.
I appreciate your interest in this important matter. Should you have additional
questions or concerns, please do not hesitate to contact me.
Enclosure
Sincerely,
(r Kris Ann Monteih
Acting Chief
Consumer and Governmental Affairs Bureau
Mignon L. Clyburn
Acting Chairwoman
FEDERAL COMMUNICATIONS COMMISSION
September 27,2013
The Honorable Robert Latta
U.S. House of Representatives
2248 Rayburn House Office Building
Washington, DC 20515
Dear Congressman Latta:
Thank you for your letter regarding the Commission's efforts to ensure that the
Video Relay Service (VRS) program is free from waste, fraud and abuse and providing
the maximum intended benefit to the deaf and hard-of-hearing communities. I instructed
Kris Monteith, Acting Chief ofthe Consumer and Governmental Affairs Bureau, to
coordinate a response to your questions. I appreciate your interest in this matter and am
pleased to provide the enclosed letter responding to your inquiry.
If you have any further questions, please don't hesitate to contact me.
Sincerely,
Mignon L. Clyburn
Enclosure
445 12'' Street S.W. Washington, D.C. 20554 (202) 418-1000
Federal Communications Commission
Washington, D.C. 20554
September 27,2013
The Honorable Robert Latta
U.S. House of Representatives
2248 Rayburn House Office Building
Washington, DC 20515
Dear Congressman Latta:
Thank you for your letter regarding the Video Relay Service (VRS) program.
Enclosed please find responses to your questions which have been provided by experts
within the Commission's Consumer and Governmental Affairs and Enforcement
Bureaus, as well as the Offices of the General Counsel, Managing Director, and Strategic
Planning & Policy Analysis, each of whom play an important role in the administration
and oversight ofthe VRS program.
I appreciate your interest in this important matter. Should you have additional
questions or concerns, please do not hesitate to contact me.
Enclosure
Sincerely,
Kris Ann Monteih
Acting Chief
Consumer and Governmental Affairs Bureau
FEDERAL COMMUNICATIONS COMMISSION
Mignon L. Clyburn
Acting Chairwoman September 27, 2013
The Honorable Greg Walden
Chairman
Subcommittee on Communications and Technology
Committee on Energy and Commerce
U.S. House of Representatives
2125 Rayburn House Office Building
Washington, DC 20515
Dear Chairman Walden:
Thank you for your letter regarding the Commission's efforts to ensure that the
Video Relay Service (VRS) program is free from waste, fraud and abuse and providing
the maximum intended benefit to the deaf and hard-of-hearing communities. I instructed
Kris Monteith, Acting Chief of the Consumer and Governmental Affairs Bureau, to
coordinate a response to your questions. I appreciate your interest in this matter and am
pleased to provide the enclosed letter responding to your inquiry.
If you have any further questions, please don't hesitate to contact me.
Sincerely,
~X.~
Mignon L. Clyburn
Enclosure
445 I2'h Street S.W. Washington. D.C. 20554 (202) 418-1000
Federal Communications Commission
Washington, D.C. 20554
September 27,2013
The Honorable Greg Walden
Chairman
Subcommittee on Communications and Technology
Committee on Energy and Commerce
U.S. House of Representatives
2125 Rayburn House Office Building
Washington, DC 20515
Dear Chairman Walden:
Thank you for your letter regarding the Video Relay Service (VRS) program.
Enclosed please find responses to your questions which have been provided by experts
within the Commission's Consumer and Governmental Affairs and Enforcement
Bureaus, as well as the Offices of the General Counsel, Managing Director, and Strategic
Planning & Policy Analysis, each of whom play an important role in the administration
and oversight of the VRS program.
I appreciate your interest in this important matter. Should you have additional
questions or concerns, please do not hesitate to contact me.
Enclosure
Sincerely,
~
fJ Kris Ann Monteih
Acting Chief
Consumer and Governmental Affairs Bureau
Mignon L. Clyburn
Acting Chairwoman
FEDERAL COMMUNICATIONS COMMISSION
September 27, 2013
The Honorable Joe Barton
U.S. House of Representatives
2107 Rayburn House Office Building
Washington, DC 20515
Dear Congressman Barton:
Thank you for your letter regarding the Commission's efforts to ensure that the
Video Relay Service (VRS) program is free from waste, fraud and abuse and providing
the maximum intended benefit to the deaf and hard-of-hearing communities. I instructed
Kris Monteith, Acting Chief of the Consumer and Governmental Affairs Bureau, to
coordinate a response to your questions. I appreciate your interest in this matter and am
pleased to provide the enclosed letter responding to your inquiry.
If you have any further questions, please don't hesitate to contact me.
Sincerely,
Mignon L. Clyburn
Enclosure
445 12" Street S.W. Washington, D.C. 20554 (202) 418-1000
Federal Communications Commission
Washington, D.C. 20554
September 27, 2013
The Honorable Joe Barton
U.S. House of Representatives
2107 Rayburn House Office Building
Washington, DC 20515
Dear Congressman Barton:
Thank you for your letter regarding the Video Relay Service (VRS) program.
Enclosed please find responses to your questions which have been provided by experts
within the Commission's Consumer and Governmental Affairs and Enforcement
Bureaus, as well as the Offices of the General Counsel, Managing Director, and Strategic
Planning & Policy Analysis, each of whom play an important role in the administration
and oversight of the VRS program.
I appreciate your interest in this important matter. Should you have additional
questions or concerns, please do not hesitate to contact me.
Enclosure
Sincerely,
~ Kris Ann Monteih
Acting Chief
Consumer and Governmental Affairs Bureau
•
Responses to Questions on Video Relay Service Program
Committee on Energy & Commerce
Oversight & Investigations Subcommittee
1) How does the FCC, in coordination with the Interstate TRS Fund Administrator,
determine what constitutes the "reasonable" costs of providing VRS services? Does the
FCC conduct its own independent evaluation ofVRS costs or does it rely solely on the
representations ofVRS providers seeking compensation from the Fund? If the latter, how
does the FCC verify this information?
Response: Both the Commission and the Fund Administrator have a role in
evaluating the reasonable costs of providing VRS. As an initial matter, the
Commission determines which categories of costs are reasonably attributable to the
provision of TRS, and rejects those categories that are not.1
Then, with respect to cost data submitted by providers, the Fund Administrator has
the responsibility, in the first instance, to ensure the accuracy and reasonableness of
such data and to ensure that reimbursement is provided only for costs the
Commission has allowed. The Fund Administrator may "examine, verify, and audit
data received from TRS providers as necessary to assure the accuracy and integrity
of fund payments."1 In order to further test the provider-supplied information, the
Consumer and Governmental Affairs Bureau authorized $3,000,000 in funding for
service provider audits in the most recent TRS rate order.3
2) Why did the FCC initially reject the TRS Fund Administrator's proposal for a sharper
reduction in VRS compensation rates beyond those established in June 2010?
Response: In June 2010, the Commission began a review of the structure of the VRS
program, taking both immediate and long-term steps to address rates and the
sustainabillty of the vital service. To address compensation rates immediately, the
1 See, e.g., Telecommunications Relay Services and Speech-to-Speech Services for Individuals with Hearing and
Speech Disabilities, CG Docket No. 03-123, Report and Order and Declaratory Ruling, 22 FCC Red 20140, 20169,
'1!75 (2007) (2007 TRS Rate Methodology Order) (concluding that indirect overhead costs are not reasonable costs
of providing TRS); id. at 20170, 'II 80 (financial transaction costs or fees unrelated to the provision of relay service
are not compensable as reasonable costs of providing service); id. at para 82 (costs attributable to relay hardware and
software used by the consumer, including installation, maintenance costs, and testing are not compensable from the
Fund.).
2 47 C.F.R. § 64.604(c)(5)(iii)(D)(6). See also Letter from David VanRoekel, Managing Director, FCC, to David
Rolka, Rolka Loube Saltzer Associates, 26 FCC Red 5099, 5100-01 (Apr. 5, 2011) (directing the Fund
Administrator to, inter alia, ''verify the accuracy of the data submitted by the providers to ensure that, with respect
to projected costs, the costs are reasonable and recoverable under the guidelines set forth in the Commission's rules
and orders.").
3 See Telecommunications Relay Services and Speech-to-Speech Services for Individuals with Hean·ng and Speech
Disabilities; Structure and Practices of the Video Relay Service Program, CG Docket Nos. 03-123 and 10-51, 28
FCC Red 9219,9226 'IJ 22 (2013) (TRS Rate Order).
1
Commission considered the TRS Fund Administrator's proposal, as well as the
concerns expressed by users and providers regarding the impact of a significant and
sudden cut to providers' compensation on the VRS program.4 The interim VRS
rates adopted in June 2010 represented the average ofthe then-existing tiered rates
and the rates proposed by the TRS Fund Administrator, and reflected a balance
between the goal of ensuring that VRS providers recovered from the Fund only the
reasonable costs caused by their provision of VRS and the goal of ensuring quality
and sufficient service during the Commission's consideration of structural reforms.5
Nevertheless, the June 2010 rate reduction was a significant one. This 18.75% cut in
the compensation rate for the bulk of VRS traffic marked the first substantial VRS
rate reduction in six years. 6 On the same day, the Commission unanimously
adopted a Notice of Inquiry to initiate a comprehensive review of the rates,
structure, and practices of the VRS program, seeking to sustain the VRS program
in the long-term and make it less susceptible to the waste, fraud, and abuse that had
burdened it in the past7
3) Why did the FCC allow VRS compensation rates for the 2011-2012 and 2012-2013 Fund
Years to remain unchanged despite its own recognition that these rates were "set
significantly higher than actual VRS costs .... "?
Response: The Commission in 2011 and 2012 was actively considering the VRS
market structure and compensation method proposals (raised initially in a June
2010 Notice of Inquiry and then in a December 2011 Further Notice of Proposed
Rulemaking) related to the structure and practices as part of a comprehensive
review of the VRS program. 8 The Commission concluded that extending the
interim rates and compensation structure provided the best means to ensure
stability and certainty for VRS users while the Commission continued to evaluate
the issues and the substantial record developed in response to that proceeding.9
While that proceeding was underway, however, the Commission took a number of
4 Telecommunications Relay Service and Speech-to-Speech Services for Individuals with Hearing and Speech
Disabilities, CG Docket No. 03-123, Order, 25 FCC Red 8689, 8695,, 12 (2010) (2010 TRS Rate Order).
s 2010 TRS Rate Order, 25 FCC Red at 8690,, 2.
6 Structure and Practices of the Video Relay Service Program, Telecommunications Relay Services and Speech-to­
Speech Services for Individuals with Hearing and Speech Disabilities, CG Docket Nos. 10-51 and 03-123, Report
and Order and Further Notice of Proposed Rulemaking, 28 FCC Red 8618, 8693, , 184 (20 13) (VRS Structural
Reform Order).
7 Structure and Practices of the Video Relay Service Program, CG Docket No. 10-51, Notice oflnquiry, 25 FCC
Red 8597 (2010) (2010 VRS NO!).
8 2010 VRS NO!, 25 FCC Red 8597 (2010); Structure and Practices of the Video Relay Service Program,
Telecommunications Relay Services and Speech-to-Speech Services for Individuals with Hearing and Speech
Disabilities, CG Docket Nos. I 0-51 and 03-123, Further Notice of Proposed Rulemaking, 26 FCC Red 17367 (20 11)
(2011 VRS FNPRM).
9 See Telecommunications Relay Services and Speech-to-Speech Services for Individuals with Hearing and Speech
Disabilities; Structure and Practices of the Video Relay Service Program, CG Docket Nos. 03-123 and 10-51,
Order, 26 FCC Red 9972,9974-75,,7 (2011) (2011 TRS Rate Order); Telecommunications Relay Services and
Speech-to-Speech Services for Individuals with Hearing and Speech Disabilities; Structure and Practices of the
Video Relay Service Program, CG Docket Nos. 03-123 and 10-51, Order, 27 FCC Red 7150, 7154,, II (2012)
(2012 TRS Rate Order).
2
significant steps to curb waste, fraud, and abuse that could threaten the program's
viability10
On June 10, 2013, the Commission released the VRS Structural Reform Order, which
set out a number of significant structural reforms and initiated a transition from
existing tiered compensation rates toward a unitary, market-based compensation
rate.11 That transition will cut rates by more than 30% over the next four years.
4) How did the Interstate TRS Fund Administrator calculate the carrier contribution factor
for the 2013-2014 Fund Year? What accounts for the more than 100 percent increase in
the carrier contribution factor between the 2012-2013 and 2013-2014 Fund Years?
Response: The Fund Administrator, Rolka Loube Saltzer Associates (RLSA), filed
the "Interstate Telecommunications Relay Services Fund Payment Formula and
Fund Size Estimate" report with the Commission on May 1, 2013.12 In this
document, RLSA provides an explanation of bow it calculated the contribution
factor, as well as a detailed explanation of the reasons for the growth in the
contribution factor. The document is attached.
As a result of the Commission's emergency rules adopted for IP CTS, a finding
regarding IP Relay outreach costs, and the lower compensation rates adopted in the
VRS Structural Reform Order, projected demand for these services decreased, and
the Commission was able ultimately to adopt a contribution factor far below the
TRS Fund Administrator's recommendation.13
For Fund Year (FY) 2012-2013, the Commission adopted:
o Funding requirement: $711.4 million
o Contribution factor: .01053
10 See, e.g., Structure and Practices of the Video Relay Service Program, CG Docket No. 10·51, Declaratory Ruling,
25 FCC Red 1868 (CGB 201 0) (Compensable VRS Calls Declaratory Ruling) (reiterating the scope of compensable
VRS calls and curbing certain abusive practices); see also Hands On Video Relay Services, Inc., Go America, Inc.,
and Purple Communications, Inc., Order and Consent Decree, 25 FCC Red 13090 (2010) (approving settlement for
in excess of $22 ntillion of alleged rule violations involving abuse of the TRS Fund); Structure and Practices of the
Video Relay Service Program, CG Docket No. I 0-51, Report and Order and Further Notice of Proposed
Rulemaking, 26 FCC Red 5545 (2011) (VRS Call Practices R&O) (adopting rules to detect and prevent fraud and
abuse in the provision ofVRS); Structure and Practices of the Video Relay Service Program, Second Report and
Order and Order, CG Docket No. 10-51, 26 FCC Red 10898 (2011) (2011 iTRS Certification Order) (revising the
provider certification process to ensure that providers of Internet-based TRS (iTRS), including VRS, receiving
certification are qualified to provide services in compliance with the Commission's rules); Structure and Practices of
the Video Relay Service Program; Healinc Telecom, UC, Request for Reimbursement of July 2011 and August 20//
Video Relay Service Minutes, Order, CG Docket No. 10-51, 27 FCC Red 9314 (2012) (denying payment to Healinc,
a VRS provider, of amounts withheld by the TRS Fund adntinistrator for non-compliance with the TRS rules).
11 VRS Structural Reform Order, 28 FCC Red 8618.
12 Rolka Loube Saltzer Associations, LLC, In the Matter of Telecommunications Relay Services and Speed-to­
Speech Services for Individuals with Hearing and Speech Disabilities; Structure and Practices of the Video Relay
Service Program, CG Docket Nos. 03-123 and 10-51, Interstate Telecommunications Relay Services Fund Payment
Formula and Fund Size Estimate, Report (filed May I, 2013).
13 TRS Rate Order, 28 FCC Red. 9219, 9220, ~ 4.
3
The original proposal from RLSA in the rate filing for FY2013-2014 was:
o Fund Requirement: $1,543,602,649
o Proposed Contribution factor: 0.02327
Following changes in the projected demand for FY2013-2014, the Commission
ultimately adopted:
o Fund Requirement: $995,533,697
o Proposed Contribution Factor: 0.01484
5) Please state when the "structural reforms" proposed in the FCC's June I 0, 2013 Report
and Order and Further Notice of Proposed Rulernaking will be fully implemented.
Response: In the VRS Structural Reform Order, the Commission adopted a number
of structural VRS reforms as modifications of the reform measures previously
proposed.14 Implementation of the reforms requires the development of new
systems, such as a VRS access technology reference platform, an application which
will be developed using consensus interoperability and portability standards and
will enable the use of off-the-shelf tablets and smartphones for VRS; 15 a central TRS
user registration database, which will help combat fraud, waste, and abuse by
ensuring VRS user eligibility;16 and a neutral video communication service
platform, which will encourage competition and innovation in VRS call handling
services by lowering barriers to entry for eligible relay providers.17 The VRS
Structural Reform Order states that these systems will be built by contractors and
the Commission is preparing a solicitation for bids. Although the VRS Structural
Reform Order did not set specific deadlines for the completion of these projects, the
Commission is committed to ensuring reform implementation occurs quickly and
efficiently. Pending implementation of the structural reforms, the Commission also
initiated in the VRS Structural Reform Order a series of incremental rate reductions,
every six months, over a four-year period.18 By the end of this process, these new
rates for the bulk of VRS traffic will be 31.2% below existing rates and 44.1% below
the rates in place before the 2010 interim rate order. The Commission's Order will
thus significantly reduce the costs of operating the program while ensuring stability
for providers and users until the structural reforms are completed.
The Commission also adopted additional reforms that will be in place while
structural changes occur, such as rules to prohibit practices resulting in waste,
fraud, and abuse, to require adoption of regulatory compliance plans subject to
14 Structure and Practices of the Video Relay Service Program, Telecommunications Relay Services and Speech-to­
Speech Services for Individuals with Hearing and Speech Disabilities, CG Docket Nos. 10-51 and 03-123, Report
and Order and Further Notice of Proposed Rulemaking, 28 FCC Red 8618 (2013) (VRS Structural Reform Order).
1l ld. at 8644-47, mJ 53-61.
16 Id. at 8647-53, ~ 68-77.
17 Id. at 8656-63, mJ 87-115.
18 Id. at 8703-06, ~ 212-216.
4
Commission review, and to protect relay consumers from unauthorized default
provider changes, known as "slamming."19
Why is the FCC, according to its June 10,2013 Order, waiting to set final VRS
compensation rates until after these reforms are fully implemented?
Response: The Commission expects the reforms to substantially change the way the
service is provided and necessarily change the compensation regime. For example,
after completion of the neutral video communication service platform, providers
who choose to make use of the neutral platform will no longer be comRensated for
the provision of the video communication service component of VRS. Final
compensation rates for these providers cannot be set until the neutral platform is
completed.
In addition, the Commission concluded in the VRS Structural Reform Order that
cost-of-service ratemaking, especially in the VRS context, is inherently a
contentious, complicated, and imprecise process.11 Therefore, the Commission has
proposed to improve the VRS compensation process by transitioning to a new
ratemaking approach that makes use of contract prices set through a competitive
bidding process, where feasible.22 Specifically, the Commission proposed that the
contract price paid to the neutral provider of the video communication service
platform serve as a benchmark for setting appropriate compensation for those VRS
providers that choose to continue offering the video communication service
component ofVRS on their own.13 The Commission also proposed that a portion of
VRS traffic be allocated by auction, thereby permitting the establishment of a
market-based compensation rate for the provision of the communications assistant
component of VRS.14 This more market-based approach, the Commission expects,
will result in compensation rates that more accurately reflect the actual costs of
providing VRS.
Why is the FCC recommending that 2013-2014 Fund Year VRS compensation rates be
brought "closer" to provider costs as opposed to being set at "actual" provider costs?
Response: The Commission found that while interim VRS compensation rates set in
2010 had begun to close the gaps between rates and costs, the cost of providing VRS
had decllned significantly over the relevant period.15 Certain large VRS providers,
however, stated that, in part due to the need to make interest payments on long­
term debt (payments that are not reimbursable from the TRS Fund to the extent
that they exceed the authorized return on investment), they could not continue
providing service if rates were reduced immediately to the level of costs. While not
19 d t . at 8624, 'IJ9.
20 Id. at 8607, '1!219.
21 Id. at 8706-07, '1!217.
22 Id.
23 Id. at 8707-08, '1!222.
24 Jd. at 8708-10, '11'1!223-235.
"Id. at 8694, 'IJ188.
5
condoning any provider's incurrence of excessive costs, the Commission recognized
that immediate imposition of a fully cost-based rate would result in a significant and
sudden cut to providers' compensation with potentially negative consequences for
VRS consumers.26 As a result, the Commission established a rate plan under which
VRS compensation rate levels move steadily downward in the direction of actual
allowable costs. 27 Reduced in increments every six months, the glide path
significantly lowers compensation rates over the next four years by over 30% while
providing predictability and ensuring the continuation of quality offerings for this
vital communications service.''
The Commission expects that this plan, which will remain in effect until the
implementation of structural reforms, will permit service providers to continue
offering VRS in accordance with the Commission's high standards for relay service
pending the linplementation of a disaggregated, market-based compensation
methodology.29 The Commission will continue to require the submission of cost
data by providers, and it reserves the right to revisit VRS compensation rates if
provider data shows that, notwithstanding the new rate plan, further rate
adjustments are appropriate.30
6) Is the FCC currently investigating any allegations of waste, fraud or abuse in the VRS
program or any particular VRS provider? If so, what are the reasons for and current status
of those investigations?
Response: The Commission's Enforcement Bureau is currently investigating
multiple providers of iTRS, including not only VRS but also IP Relay and IP CTS.
The VRS investigations in particular are focused on improper billing of the TRS
Fund for, among other things, calls made with Internet applications that allowed
users to make but not receive VRS calls, and calls made by providers' own
employees and subcontractors.
The Commission's Enforcement Bureau also has concluded nearly 30 investigations
involving iTRS. Five of these resulted in consent decrees, and collectively required
the providers to reimburse nearly $30,250,000 to the TRS Fund, to pay over
$23,750,000 to the U.S. Treasury, and to adopt compliance plans designed to prevent
future misconduct.31 Another twenty-three investigations resulted in citations to
providers for illegal operators; twenty-one of these providers cited subsequently
ceased operations, and the other two corrected course and obtained the necessary
FCC certifications to provide VRS.
26 !d. at 8703-04, 1)212.
27 Id. at 8703-06, 1!11212-216.
28 !d.
29 !d. at 8706, 1)216.
30 !d.
31 Sorenson Communications, Inc., DA 13-1068, Order, 28 FCC Red 7841 (2013); AT&T Inc., DA 13-594, Order,
28 FCC Red 5994 (2013); American Network, Inc., DA 13-444, Order, 28 FCC Red 2816 (2013); CSDVRS, UC
d/b/a/ ZVRS, DA 12-1844, Order, 27 FCC Red 14172 (2012); Hands on Video Relay Services, Inc., Go America,
Inc., and Purple Communications, Inc., DA 10-1734, Order, 25 FCC Red 13090 (2010).
6